ML20024D237
| ML20024D237 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/01/1983 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 7971N, NUDOCS 8308030355 | |
| Download: ML20024D237 (13) | |
Text
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Commonwealth Edison i ) One First Nation *J Plua. Chictgo, lihnois Address Reply to: Post Office Box 767 v
Chicago, Illinois 60690 l
August 1, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Unit 2 Conformance to 10CFR50.49 Requirements NRC Docket No.
50-374
Dear Mr. Denton:
Commonwealth Edison submitted an environmental qualification status report on May 29, 1983 in response to the requirements of the new rule.
Coverage for that report included all safety-related equipment:
active mechanical equipment and that ghelasgd{EapparatusintheHARSHandnon-harshenvironmentalzones.
splay " equipment, or those devices referenced by the operator to accomplish the Emergency Procedures Guideline actions, was also included in the status list.
The items identified as "important to safety" because of their potential interaction with safety - related systems or equipment with safety functions were specifically treated via responses to Questions 031.288 - through 296.
The remaining part of the coverage is that equipment designated as Reg Guide 1.97 equipment for the post-accident monitoring of plant status.
This letter addresses this last category of equipment.
The attached table is provided to indicate the environmental qualification status of the Reg Guide 1.97 equipment.
Listed in the table are those Category 1 and Category 2 paramenters with the associated LaSalle equipment by part number which meets the scope of Reg Guide 1.97 consistent with Edison's complicance position of June 29, 1982 (Letter C.W. Schroeder to A. Schwencer).
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. Equipment providing control room indication of each parameter, its model number and manufacturer, and qualification status is indicated.
The applicable qualification standard is NUREG 0588 Category II which is the LaSalle requirement, except for replacement equipment.
In those cases where qualification of equipment is potentially HARSH environments is not complete, a discriptive summary of planned actions or test progress is given, and a justification for interim operation is provided.
This record establishes the fact that the equipment which provides control room indication of plant parameters, defined under Reg Guide 1.97 as necessary to determine the condition of the plant following an accident, are now or will be environmentally qualified by the March 31, 1985 terminal date.
To the best of my knowledge and belief the statements contained herein and in the enclosure are ture and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Very truly yours, w -___ ;
C.
W. Schroeder N
ear Licensing Administrator bg 7971N
Manufacturer Pa rameter Existing Equipment and Model Oualification Status A1. H2 concentration AIR-CM012 (indic.)
Westronics, D4E Mild environment application and 02 conc.
PL76J (analyzer)
Comsip, Inc., K-IV Qualification efforts in progress C11.
AIR-CM018 (indic.)
Westronics, D4E Mild environment. application C12.
PL77J (analyzer)
Comsip, Inc., K-IV Qualification efforts in progress A2. RPV Pressure B21-R884A&B (indic.)
Westronics, D4E Mild environment application B6.
B21-K613A&B (pwr)
GE, 9T66Y987 Mild environment application C4.
B21-N051A&B (sensor)
Bailey, KG556 Will be replaced with a qualified instr.
C9.
A3. Suppression Pool TR-CM037 (indic.)
Westronics, MllE Mild environment application Water Temperature TR-CM038 (indic.)
Westronics, MllE Mild environment application TY-CM057AA (conv.)
Love Controls, 54 Qualified TY-CM057UB (conv.)
Love Controls, 54 Qualified 4
TE-CM057A-V (sensor)
Weed, 611 Qualified A4. Suppression Pool UR-CM031 (indic.)
Westronics, D4E Mild environment application Water Level EY-CM082 (pwr)
Kepco, PCX-72-0.3 Mild environment application C7.
LT-CM032 (sensor)
Rosemount, 1152 Will be replaced with a qualified instr.
UR-CM029 (indic.)
Westronics, D4E Mild environment application EY-CM083 (pwr)
Kepco, PCX-72-0.3 Mild environment application LT-CM030(sensor)
Rosemount, 1152 Will be replaced with a qualified instr.
AS. Drywell Pressure UR-CM029 (indic.)
Westronics, D4E Mild environment application B7.
EY-CM083 (pwr)
Kepco, PCX-72-0.3 Mild environment application 89.
PT-CM029 (sensor)
Rosemount, 1152 Qualified C8.
UR-CM031 (indic.)
Westronics, D4E Mild environment application C10.
EY-CM082 (pwn)
Kepco, PCX-72-0.3 Mild environment application PT-CM031 (sensor)
Rosemount, 1152 Qualified Bl. Neutron Flux C51-R603A-D (IRM meter)
~ Bailey 732233AAAA1FAA Mild environment application
_C51-K601A-H (IRM cony.)
GE, 368X102AA _
Mild environment application Mild environment application C51-K002A-H (IRM preamp)
GE, 828E309AA C51-N002A-H (IRM det.)
GE, 112C3144 Qualification efforts in progress
'H13-P608 (indic. & avg.)
GE, 791E597 TD Mild environment application
_B13-D193(all) (LPRM sensor)
GE, NA200
. Qualification efforts in progress t
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Manufacturer Parameter Existing Equipment and Model Qualification Status B4. Reactor Water B21-R884A&B (indic.)
Westronics, D4E Mild environment application Level B21-K613A&B (pwr)
GE, 9T66Y987 Mild environment application B21-N026A&B (sensor)
Barton, 760 Qualification efforts in progress B21-R604 (indic.)
GE, 159C4540P14559 Mild environment application B33-K600 (pwr supply)
GE, 9T66Y987 Mild environment application B21-f026C (sensor)
Barton, 760 Qualification efforts in progress B10. Containment Group 1 Isolation Valve B21-F019 Limitorque Qualified Position B21-F016 Limitorque Qualified B21-F067 Limitorque Qualified MSIV's B21-F022A-D Namco, EA-740 Qualified i
B21-F028A-D Namco, EA-740 Qualified
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Group 2 IN074 Namco, EA-180 Qualified IN075 Namco, EA-180 Qualified CM017A&B Valcor Qualified 4
CM018A&B Valcor Qualified CM019A&B Valcor Qualified CM020A&B Valcor Qualified CM029 Valcor Qualified CM030 Valcor Qualified CM031 Valcor Qualified CM032 Valcor Qualified CM033 Valcor Qualified CM034 Valcor Qualified IN001A&B Namco, EA-180 Qualified i
WR029 Limitorque Qualified WR040 Limitorque Qualified WR179 Limitorque Qualified WR180 Limitorque Qualified B33-F338A&B Valcor Qualified B33-F339A&B Valcor Qualified B33-F340A&B Valcor Qualified B33-F341A&B Valcor Qualified
Manufacturer Parameter Existing Equipment and Model Qualification Status 810. Containment Group 2 (cont'd) j Isolation Valve RE024 Namco, EA-180 Qualified Position
.RE025 Namco, EA-180 Qualified RE026L Namco, EA-180 Qualified RE029 Namco, EA-180 Qualified RF012 Namco, EA-180 Qualified RF013 Namco, EA-180 Qualified B33-F342A&B Valcor Qualified B33-F343A&B Valcor Qualified 6
4 B33-F344A&B Valcor Qualified B33-F345A&B Valcor Qualified VP053A&B L imitorque VP063A&B Limitorque VP113A&B Limitorque 4
VP114A&B Limitorque IN017 Namco, EA-180 Qualified IN031 Valcor Qualified B21-F032A&B Namco, EA-180 Qualified Indication is given Mild environment application by various lights i
t in the main control i
room.
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. Manufacturer Parameter Existing Equipment
__and Model Qualification Status C5. Primary Contain.
RR-CM011 (indic.)
Westronics, S4E Mild environment application Area Radiation RIT-CM011 (transmitter)
Gen. Atomics, RP2C Mild environment application RE-CM011 (sensor)
Gen. Atomics, RD23 Qualification efforts in progress RR-CM017 (indic.)
Westronics, S4E Mild environment application RIT-CM017 (transmitter)
Gen. Atomics, RP2C Mild environment application i
RE-CM017 (sensor)
Gen. Atomics, RD23 Qualification efforts in progress C13. Containment D18-R800 (indic.)
Westronics, M11E Mild environment application Effluent Rad.
D18-R801 (indic.)
Westronics, D4E Mild environment application D18-R803 (indic.)
Westronics, D4E Mild environment application D18-R804 (indic.)
Westronics, D4E Mild environment application PL58JA&B (monitor)
Gen. Atomics Mild environment application D3. Suppression E12-R603A&B (RHR flow indic.)
GE, 180 Mild environment application Spray Flow E12-K603A&B (pwr)
GE, 9T66Y989 Mild environment application E12-N015A&B (sensor)
Rosemount, 1151 Will be replaced with a qualified instr.
D7. Drywell Air TR-CM037 (indic. )
Westronics, MllE Mild environment application Temperature TE-CM058 (sensor)
Weed, E4B Qualified TE-CM059 (sensor)
Weed, E4B Qualified TR-CM038 (indic.)
Westronics, M11E Mild environment application TE-CM060 (sensor)
Weed, E4B Qualified TE-CM061 (sensor)
Weed, E4B Qualified D9. MSIV Leakage E32-N061A-N Rosemount, 1152 Mild environment application Control System E32-N661A-N Bailey, 745 Mild environment application Pressure D10. SRV Position B21F013A-V (sensor)
Crosby, LVDT Qualified D13. RCIC Flow E51-R606 (indic.)
GE, 180 Mild environment application C61-K010 (pwr)
GE, 9T66Y987 Mild E51-N003 (sensor)
Rosemount, 1151 Will be replaced with a qualified instr.
D14. HPCS Flow E22-R603 (indic.)
GE, 180 Mild environment application E22-K600 (pwr)
GE, 9T66Y989 Mild environment application E22-N005 (sensor)
Rosemount, 1152 Will be replaced with a qualified instr.
D15. LPCS Flow E21-R600 (indic.)
GE, 180 Mild environment application E21-K603A (pwr)
GE, 9T66Y989 Mild environment application i
E21-N003(sensor)
Rosemount, 1151 Will be' replaced with a qualified instr.
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Manufacturer Parameter Existing Equipment and Mod?1 Qualification Status D19. RHR Flow E12-R603A-C (indic.)
GE, 180 Mild environment application E12-K603A-C (conv.)
GE, 9T66Y989 Mild environment application E12-N015A-C (sensor)
Rosemount, 1151 Will be replaced with a qualified instr.
D20. RHR HX Outlet E12-R601A&B GE, 235A1136P002 Mild environment application Temperature E12-N027A&B Pyco Qualification efforts in progress D21. CSCS Temperature E12-R601 GE, 235A1136P002 Mild environment application E12-N005A,B Pyco Qualification efforts in progress D22. CSCS Flow E12-R602A&B (indic.)
GE, 180 Mild environment application E12-K603A&B(cony.)
E12-N007A&B (sensor)
GE, 9T66Y989 Mild environment application Rosemount, 1151 Will be replaced with a qualified instr.
D24. Emergency VR04YA&B Techno Corp.
Mild environment application Damper Position VR05YA&B Techno Corp.
Mild environment application OVC52YA&B Powers Regulator Mild environment application D25. Status of II-DG019 (indic.)
GE, DB40 Mild environment application j
Standby Power IT-DG019 (current xmtr)
GE,20-500 Mild environment application Supplies JI-DG022 (indic.)
GE, DB40 Mild environment application JT-DG022 (power xmtr)
GE,20-610 Mild environment application Indication is given by Mild environment application various lights in the main control room.
Note unit prefixes are "O,
1, and 2".
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A1. H2 and 02 Concentrations PL76J, PL77J Qualification Status Efforts are continuing with the vendor to both qualify the sample pump to a LaSalle-specific radiation level and to answer questions relating to catalyst poisoning.
Additionally, measures have been identified to relocate the sensitive electronics to an area subject to less harsh post-DBA conditions.
Justification for Interim Operation These items are exposed to harsh conditions for an Instrument Line Break out-side of containment or for the high radiation associated with a LOCA.
Failure of these devices will affect the capability to sample the H -02 percentages 2
inside the primary containment; this capability is not needed for the line break. With respect to the LOCA, justification for interim operation is established by the limited testing done to date which shows acceptable per-formance in harsh conditions less severe than LaSalle's (both radiation and iodine poisoning tests). Also, credit must be taken for LaSalle's inerted containment.
A2.
RPV Pressure B21-N051A, B Qualification Status These Bailey transmitters will be replaced with Rosemount 1153 transmitters, which are fully qualified to NUREG 0588 Cat. I for this environment.
Justification for Interim Operation These devices may be subject to a harsh environment for an Instrument Line Break outside of containment or from the high radiation associated with a LOCA inside containment. Since this device is not required in the Instrument Line Break event, only the LOCA need be considered.
These devices provide information to the main control room and do not impact any automatic functions. Alternate infonnation is available to the operator from other pressure instrumentation. The operator will take action in ac-cordance with the emergency procedures to maintain reactor level and core cooling functions. No other systems are affected by the failure of this device.
A4.
Suppression Pool Water Level LT-CM030, LT-CM032 Qualification Status These instruments will be upgraded from a Rosemount 1152 to a 1153 pressure transmitter, which is fully qualified to NUREG 0588 Cat. I for this environment.
Justification for Interim Operation These devices are exposed to harsh environments for an Instrument Line Break inside the HPCS cubicle and for the high radiation which follows a LOCA.
Since the device is not required for the Line Break event, only the LOCA need be considered.
Since these instruments provide infonnation only and do not impact any safety functions, loss of the instruments will not preclude safe shutdown. Alternate information is available to the operator, who will take action in accordance with the emergency procedures. No other systems are affected by the failure of these devices.
Bl. Neutron Flux C51-N002A-H
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Qualification Status Power range equipment is not in our EQ program.
Intennediate range equipment is included in the EQ program. A test on the weak link, the connector, is ongoing at Wyle Laboratories. This test report will close out the documentation requirements.
Justification for Interim Operation The primary concern for monitoring neutron flux in a postaccident situation is not to detect approach to criticality but approach to the point of adding heat. Criticality by itself does not pose any threat to the fuel boundary or the environment. The threat occurs after criticality when power ha - Roched the point of adding heat. Criticality does. not occur at a fixed power level but varies with moderator temperature, time since shutdown, core life and other variables. The point of adding heat, however, will always occur at 1% power, which simplifies the indication the operator must be aware of.
Once the reactor has been shut down by inserting all control rods, it will remain subcritical until those rods are once again withdrawn.
Even with the most reactive control rod removed, the reactivity control systems will keep the reactor subcritical.
An acceptable range for the neutron flux monitoring should be 10-2 percent, l
which gives the operator 2.0 decades to monitor neutron flux before adding heat.
Actual reactor power levels corresponding to the IRM range are 1 X 10-4% to about'40% power. This range is adequate to monitor 3.0 decades of monitoring range before the core starts adding heat to the coolant.
Previously, the LaSalle position indicated SRM channels would meet Reg. Guide 1.97.
The information provided above justifies monitoring the low end of neutron flux with IRM's. Monitoring the upper range will be addressed in a schedule consistent with our previous commitments.
The IRM's, whose qualification is incomplete at this time, are located in the reactor vessel and are therefore normally exposed to a harsh environment.
Their function is to monitor neutron level in the reactor and provide a scram signal during start-up. Failure of these components will not affect automatic reactor scram because other variables, such as reactor pressure, are available to provide the required safety function.
During start-up, the portion of the assembly external to the vessel, the connector, will not be exposed to a harsh environment and will therefore be able to maintain electrical continuity.
In the event of a LOCA, the IRM's perform no mitigating action and need not function. Therefore, although connector integrity has not been verified, interim operation is justified.
B4. Reactor Water Level B21-N026A, B, C Qualification Status These Barton level transmitter switches will be replaced with a pressure transmitter and switch arrangement in order to meet qualification requirements.
The transmitter will be a Rosemount 1153, which is fully qualified to NUREG 0588 Cat. I.
The switch will be selected once our qualification test series at Wyle Laboratories is complete. There, we are testing a Barton 288A and a SOR 103 (prototype) side by side to determine best suitability for this environment.
Justification for Interim Operation These devices are exposed to harsh environments as a result of an Instrument Line Break and a LOCA (high radiation exposure only).
In addition to providing indication, these instruments provide a low reactor level initiation signal to the RWCU isolation valve, SGTS, and MSIV.
No other systems are affected by their failure.
Due to physical separation, failure of one instrument line will not impact the other division's components. These devices are not required when the harsh environment caused by the line break prevails and they perfonn their function prior to being affected by the LOCA radiation. With regard to the indication feature of this instrument, the operator may refer to alternate indication from other sensors and will take action in accordance with the emergency procedures.
C5. Primary Containment Area Radiation RE-CM011, RE-CM017 Qualification Status A test report is presently in-house for review and evaluation.
In anticipation 1
that additional qualification testing may be required for the connector, they are being included in a test program at Wyle Laboratories.
Justification for Interim Operation These components are exposed to harsh environments only for an Instrument Line Break outside containment and the high radiation associated with a LOCA. Their sole function is to provide signals for monitoring and recording drywell radi-ation levels; they perform no automatic function. No other system is affected by their failure. Alternate information may be obtained from the HRSS and/or the portable radiation detectors.
03.
Suppression Spray Flow, D19 - RHR Flow E12-N015A & B Qualification Status These Rosemount 1151's will be replaced with 1153's, which are fully qualified to NUREG 0588, Cat. I.
Justification for Interim Operation These transmitters sense flow from the RHR heat exchanger to the drywell spray header. They may be subject to a harsh environment for an Instrument Line Break outside of containment or from the high radiation associated with a LOCA.
These devices provide information to the main control room and do not impact any automatic functions. Alternate information is available to the operator to monitor post-accident conditions. The operator will take action in ac-cordance with the emergency procedures to maintain reactor level and core cooling functions. No other systems are affected by the failure of-this device.
D13. RCIC Flow E51-N003 Qualification Status This Rosemount 1151 will be replaced with a Rosemount 1153, which is fully qualified to NUREG 0588 Cat. I.
Justification for Interim Operation This component is located inside the RCIC/LPCS cubicle and is exposed to a harsh environment for an Instrument Line Break outside of containment and for the high radiation associated with a LOCA. For the break in the cubicle, it is' presumed to fail and therefore is not required for that event. For the LOCA event, it performs its control function (RCIC turbine initiation) prior to being affected by the radiation. Note also that in the analysis of a LOCA and HELB, no credit is taken for RCIC. With regard to the indication fed by this transmitter, the operator will follow the emergency procedures for long-term core and containment cooling.
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D14. HiCS Flow E22-N005 Qualification Status This Rosemount 1152 will be replaced with a Rosemount 1153, which is fully qualified to NUREG 0588 Cat. I.
Justificaticn for Interim Operation This device is located inside the HPCS cubicle and is exposed to a harsh en-vironment for an Instrument Line Break and the high radiation associated with a LOCA. This device is-presumed to fail for a line break in the HPCS cubicle.
For the LOCA event, it provides information only and does not initiate any automatic functions.
Its failure does not affect any other system. The operator may refer to alternate indicators to assess ' post-accident conditions and will follow the emergency procedures to provide long-tenn core and con-tainment cooling.
D15. LPCS Flow E_21-N003 Qualification Status This <.osemcunt 1151 will be replaced with a Rosemount 1153, which is fully qut;ified to NUREG 0588 Cat. I.
Justification for Interim Operation This device is located in the RCIC/LPCS cubicle and is exposed to a harsh en-vironment for an Instrument Line Break inside the cubicle and the high radi-ation from a LOCA. LPCS is considered unavailable for a break in the cubicle so this device need not be qualified for that environment. For the LOCA event, it performs its control function (control minimum flow valve) prior to being affected by the radiation. With regard to its indication signal, the operator may refer to alternate sensors to assess post-accident conditions and will follow the emergency procedures to provide long-term core and containment cooling.
D20. RHR Heat Exchanger Outlet Temperature E12-N027 Qualification Status Vendor testing is in progress to qualify this Pyco thermocouple to NUREG 0588 Cat. I.
CECO. will await the results of this test report.
.o Justification for Interim Operation This instrument is located in an area where it may be exposed to a harsh en-vironment for an Instrument Line Break outside of containment and for the high radiation associated with a LOCA.
Since its sole function is to provide con-trol room indication, its failure will not impact the performance of any safety function. The operator will rely on the emergency procedures to shut down the plant and provide long-term cooling.
D21. CSCS Temperature E12-N005A, B Qualification Status The vendor is presently qualifying these Pyco thermocouples by type test per NUREG 0588 Cat. I.
CECO. will await these test results.
Justification for Interim Operation These thermocouples measure service water temperature downstream of the RHR heat exchanger. Since this 'scrvice water source is the same as all other service water, the lake, it provides adequate indication of the water tem-perature. Although this measurement is taken downstream of the heat exchanger, the fact that it is within the proper range verifies adequate performance of the safety function and adequate service water inlet temperature.
These devices will be exposed to a harsh environment for an Instr. ment Line' Break outside of containment and for the high radiation associated with a LOCA.
Since their sole function is to provide control room indication, their failure will not impact the performance of any safety function. The operator will rely on the emergency procedures to shut down the plant and provide long-term cooling.
D22. CSCS Flow E12-N007 Qualification Status This Rosemount 1151 will be replaced with a model 1153, which is fully qualified to NUREG 0588 Cat. I for this environment.
Justification for Interim Operation This transmitter may be exposed to a harsh environment for an Instrument Line Break outside of containment or for the high radiation associated with a LOCA.
Since its sole function is control room indication, its failure will not ad-versely affect the performance of any safety function. The operator will rely on the emergency procedures to shut down the plant and to provide long-term core cooling.
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